Working with learning technology requires a working knowledge of legislation. In this section, I draw on three examples of legislation and how they influence my role:
- Part A: Data Protection Act (2018) and GDPR
- Part B: COVID-19 regulations
- Part C: Equality Act (2010) and 2018 SI
Part A: Data Protection Act (2018) and GDPR
Description
While GDPR was initially established by the European Union, it was still implemented in the United Kingdom, despite Brexit as UK GDPR. This was further tailored by the Data Protection Act (2018). As someone responsible for business processes and for technical systems that manage personal/private data, I have had to engage with GDPR in my role – and have had to support colleagues and academics in doing so too.
GDPR specified new restrictions on how data was stored, managed and processed. This included new individual rights and responsibilities for data processors and controllers. GDPR also redefined personal and sensitive data, increasing restrictions and moving some data into different categories. As part of implementing GDPR, I undertook audits across our data processors to identify what personal and sensitive data we hold. I’ve also had to work towards ensuring data is stored appropriately and in the proper territory, and that appropriate data retention policies are in place. This includes supporting colleagues and academics in doing this process also.
To ensure our customer-facing services are compliant, I have had to develop new processes in our systems. This includes new, clearer consent forms to ensure customers understand how their data are being used. We’ve also been more transparent on how and when data is moved between different processors.
Evidence:
- Passed the: Data Protection and Information Security update for GDPR and Safeguarding in HE courses.
- I undertook GDPR audits and wrote data processing plans for all Skills Team services.
- I drafted the University Library – Springshare Privacy Policy
- I contributed to internal DPIA Assessments
- I have liaised with Assurance and Legal colleagues in processing contracts to ensure GDPR guidelines are met.
- I have led Cloud Data Privacy Impact Assessments LibApps and other publisher resources.
My work provided students and academics with greater clarity on how their data was used an processed:
The above activities were fundamental to ensuring legal compliance. This allowed business continuity and ensured we operated within the law. While continuity seems a strange claim on impact – the alternative would have been service withdrawal in several areas.
NVivo Transcription Data Privacy Impact Assessment
I wanted to provide an example Data Privacy Impact Assessment that I have written. As Chair of the NVivo User Group, I led this assessment, ensuring the tool met the GDPR guidelines. To facilitate staff and student use of this tool, I then write implementation guidance (right) to assist in the safe and GDPR-compliant use of the tool.
My work on this enabled students and staff to benefit from the tool as it secure approval from the University thanks to my assessment.
GDPR is an integral part of procurement. When the regulations were first launched, I had to negotiate with suppliers to ensure their compliance. While challenging, this guaranteed continuity of service with several critical systems – that required serious pressure and negotiation to ensure full compliance. This required balancing risk carefully in accordance with ICT’s regulations.
Statement of support: Chris Awre, University Librarian, University of Hull
Lee was the system owner for our Springshare system, which captured personal information as part of providing services around appointments and calendar/workshop bookings. He was meticulous in clarifying within the system how we needed to manage the personal data held and when we needed to delete it once the stated reason we had collected it was no longer valid. This personal investment then translated into a set of processes which others could take forward, particularly helpful in Lee’s handover when he moved to a different role.
Reflection:
GDPR regulations were often seen as restrictive or problematic. In reality, I found them quite reassuring. Finally, there was very clear guidance on how data should be managed. I also found it reassuring as a consumer that restrictions were specified about where data was stored, how it was used and processed. The bigger battle has been winning the hearts and minds of those I work with. The fact this was a legal restriction didn’t seem to cut it. However, on running training sessions and explaining how and why it worked – it was easy to get people to do the right thing.
The thing that has been the most frustrating has been waiting for suppliers to make their systems compliant. I clearly recall one supplier that had failed to make any preparations for GDPR, which rendered me unable to pay them under our financial guidelines. This was a very tricky situation, but fortunately, the supplier stepped up and delivered the necessary processing and right-to-be-forgotten measures in their system. This was a relief, as the alternative would have been to move to a different system.
Part B: COVID-19 and creating a covid safe working environment for students
Description
Over the course of 2020, I have had to work hard to support the safe opening of the Brynmor Jones Library. This required the interpretation of government guidance issued to manage the Covid-19 pandemic. My first task was to establish a ‘Click and Collect’ system. While my colleagues led on the process to support this, I created the system to facilitate this online. I used Springshare’s LibCal appointments to maintain social distancing and avoid crowds at the collection point.
My other significant contribution to our safe reopening is the system and artwork for our ‘Book a Seat’ service. This enables the Library to manage capacity within the building while maintaining social distancing and facilitating contact tracing. I used Springshare’s LibCal to manage this and drew all the floorplans. I updated the consent forms to allow us to retain, collect and share data to facilitate contact tracing. At its height, the system managed over 600 seats within the Brynmor Jones Library and facilitated a checking-in and out process, allowing for padding in between. As regulations eased, we increased the number of spaces provided open-access but retained booking for our high-demand spaces and group learning rooms. This was based on an evaluation on the booking system and allowed the Library to retain key benefits of this process, even though things had returned to open access.
The pandemic has changed many of our working practices. In leading the Library Marketing and Social Media Team, I was also responsible for pushing out messages about our new service delivery model. While the Library used to proudly promote our roving staff, at the beginning of the pandemic, I had to put a new focus on automation, self-service and online contact with staff for help. This required me to fine-tune our Library Live Chat service (including the incorporation of Twitter and Facebook) and promote this as our primary source of support.
Fortunately, we have been able to reopen many of our services and re-introduce in-person support. This work was, however, vital for us in supporting our students through the worst of the pandemic.
Evidence:
Impact: One of the first University Libraries to open in the country. As a University with a proud tradition of widening-participation (7.6% part time, 43.7% mature, 13.8% BAME, 28.4% Polar4 Q1, 7.5% working class white male), this was essential to supporting our students, many of whom struggled without access to key learning facilities. My systems safely facilitated access to campus for hundreds of students.
Impact: This work enabled to safe reopening with distance-focused services. Thanks to the measures in place, there was no contact tracing involvement, or link to the Library as an outbreak source throughout the 2020-2022 period. These systems facilitated thousands of seat bookings.
Statement of support: Lisa Bolt, former member of staff, University Library, University of Hull
Myself and Lee worked together setting up and implementing the new Spring Share package called Seats. This was aimed at getting students back into the library safely during the COVID Pandemic. Lee led on procuring the package because it allowed us to control the number of students studying in the library at anyone time, set the study seating spacing so that there was a minimum of 2 meter distancing between each study seat, it provided contact tracing details of every one who booked a study seat and it also allowed us to prioritise access to University of Hull students initially.
Impact: Students couldn’t access campus, but my re-working of systems allowed support to move online (initially) and then to socially distanced (later phases). These systems facilitated hundreds of Skills Team appointments and workshop bookings.
Reflection:
Technology has been an essential aspect of our COVID-19 safe working environment. As an organisation, we had worked hard on developing our customers services – based on a model of easily identifiable staff and the encouragement of customers to come to speak with us. This model was inappropriate in the context of the pandemic. We had to switch to encouraging customers to use our Library Live Chat and Support Portal. This placed technology at the heart of our customer contact and customer services. I had to enhance our online contact systems and design new marketing to encourage their use. As you can see above, new signage and banners promoted online support. Not our staffed service points and roving staff – but our live chat, online appointments, Support Portal and online workshops instead. This felt strange as it was the opposite of our old marketing. I was, in effect, asking people to ‘go away and use a computer’ instead of coming to ask us anything. Still, it was the right thing to do – and it worked in helping us build a COVID-19-safe working environment and services.
The biggest undertaking was the seat booking system. In the space of two weeks, I had researched, procured and set up the new seat booking system. This included training our staff on how to use it and building the student-facing booking system. It was a lot of pressure to turn this around so quickly, and our supplier was terrific! I must admit, I’ve buried the stress of all this – but it was worth it. It enabled Hull University Library to be one of the first to re-open in the UK. We even shared this story in our supplier’s blog: How They Did It: Reopening at the University of Hull Library.
Part C: Equality Act (2010) and 2018 Statutory Instrument
Description
The Equality Act (2010) requires applications to be inclusive of those with protected characteristics. This was further strengthened in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 and the updated The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility (Amendment) (EU Exit) Regulations 2022. This statutory instrument was designed to make online public services more accessible, particularly for disabled people. It also required public bodies to draft Accessibility Statements that outline how their website is accessible, any exceptions to accessibility and how any exceptions will be addressed.
The Government’s Accessibility Campaign made it clear that:
Most higher and further education providers are considered to be in scope for the regulations, due to their dependence on government funding
Accessibility Campaign
This made the implementation of Accessibility Statements and general accessibility improvements important for legal compliance. I have led on aspects of the University Library’s response to this, drafting accessibility statements and developing our website to be further compliant. I’ve also used SiteImprove to audit all 900+ web pages on the Library and Skills Team website. As part of this, I have made numerous improvements – from auditing ALT text to recalculating how fonts are specified to improve accessibility across devices. Most of this work had meant writing new CSS, or adjusting existing code to be better compliant.
A significant aspect of my work on accessibility has been training colleagues to expand their knowledge and skill in this area. In practical terms, it has also been essential – there was no way I could do this work alone. By the time I left the Library, there was a team of five colleagues using SiteImprove to enhance digital accessibility – an initiative spearheaded by me. This team is much bigger when it comes to foregrounding that practice throughout the Library. I ran training on accessible communication and learning resource design – which is now mandated throughout Library services.
While I am very new to my academic post, I am applying this learning to all resources I make. More importantly, I support (and challenge) colleagues to produce work that meets accessibility standards.
Evidence:
I have recently spent a lot of time working on accessibility statements for the University Library.
- University Library – Springshare Accessibility Statement
- See further evidence in understanding and engaging with policies and standards where I talk about taking this legislation further with the use of accessibility standards.
Statement of support: Maggie Sarjantson, Collections Manager, University Library
Working with Lee helped me to develop my own practice to keep accessibility and inclusion in focus. He ran a staff development session about the accessibility features of Microsoft 365, and how to create inclusive documents. Following this I changed the format I use for document so ensure there are headings that allow navigation, the font is clear, there is sufficient colour contrast, images have alt-text descriptions, and I use the ‘Check accessibility’ function to identify any barriers to access and understanding. I also encourage others to do the same.
Statement of support: Rachel Welch, Head of Customer Services, University Library
Lee advocated for and organised a Library Accessibility Fortnight last year. This was about raising awareness of our services and spaces to ensure they are usable by everyone. Everyone was encouraged to take a fresh look at what we do and to implement any improvements that we recognised.
I worked with my colleague Jacqui Bartram to build an accessible PowerPoint template. Through my leadership of the Marketing and Communication Team, I developed a policy to make it compulsory for Library staff and had this approved by Library Management. This template has now been applied to all Skills Team teaching sessions and every single internal and external presentation done by the Library. The impact of this template represents hundreds of slides and presentations – all fully accessible and benefiting students, thanks to my work. Here are some examples of these slides in practice:
To further support colleagues in producing accessible content, I made a dedicated OneNote notebook with advice, guidance and templates for Library staff to follow. This even included suggested terminology to keep the language consistent and inclusive:
Statement of support: Paul Chin, Head of Teaching and Learning, University of Bath (former line manager)
Lee regularly trained the Skills Team and broader university staff, and his training around digital skills, for example, has had a lasting effect on my own capabilities to develop my teaching practice for promoting digital skills for students. Lee is also a massive contributor to the Learning Development community through his contribution to and involvement with ALDinHE as a member of LearnHigher.
I’ve also been invited to contribute my knowledge and experience of accessibility through several routes in the School of Education – these may be too early for demonstrable impact, but that will come:
- In School of Education seminars, I presented my Designing for Diverse Learners work (see Understanding and engaging with policies and standards).
- I’ve been invited to lead the technical implementation of Teams to improve communication and accessibility in the School.
- I’m supporting an assessment rubric working group to ensure outputs are accessible.
- I’m part of the Global Competence working group, bringing my EDI and accessibility expertise.
Reflection:
I have long been a champion of accessibility. To see this enshrined in legislation has been a vehicle for meaningful change. The new Public Sector Bodies Regulations 2018 has been everything I’ve needed to drive forward meaningful change around accessibility. I teach that if we are not accessible, we are inaccessible. If we are not inclusive, we are exclusive. These regulations have helped us drive forward are more accessible and inclusive web. It has not been easy – and we have a long way to go – but finally, the law enforces accessibility. For me, accessibility has always been a moral imperative, and I am so happy to see it driving forwards.
I had a large responsibility in driving accessibility for the University Library. A few short months into my new role, I am working this responsibility into my new setting. The School of Education has an excellent record of widening participation and specialism in inclusion. These provide ripe opportunities for me to forefront the inclusive use of technology as part of inclusion. The potential for this is HUGE – especially if I can embed these practices into not just the materials – but student learning and application. This could support a generation of graduates to leave university with the key skills they need to use technology accessibly.
References
Data Protection Act (2018) Chapter 12. Norwich: The Stationery Office.
Equality Act (2010) Chapter 15. Norwich: The Stationery Office.
The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations Order 2018 (SI 2018/852). London: The Stationery Office Ltd.
Revisions for reassessment:
I’ll be honest – this was a challenging section to revise, as I felt my work had demonstrated significant engagement with legislation. In hindsight, I realise I’ve not made that impact clear. You’ll notice new call out boxes on this page to try and better articulate that impact. I’ve also included testimonies from three colleagues to further evidence my input and impact in this area. For the large part – my work kept things running and compliant. While that does not sound like much, without my input, services would have been removed due to lack of compliance. I’ve articulated parts of this to impact my new role, and have updated grammar and style in several places. I’ve revisited reflections to add some more thoughts.